Mens Rea - Indirect/Oblique Intent

D was drunk and accidentally fired his shotgun at his father. 

Conviction was quashed on appeal. 

1. Was death or really serious injury a natural consequence of the defendants act? 

2. Did the defendant foresee that consequence as being a natural result of his act?

Did not include the word 'probable'. Overrulled in Hancock and Shankland (1986) 

D's were miners on strike, pushed a block into the road to stop taxi with a co-worker inside. Block killed driver. 

CoA quashed conviction of murder. 

Lord Scarman said the Maloney guidelines were 'unsafe and misleading'. 

D put paraffin through womans letterbox of whom he held a grudge.

Child inside the house died.

CoA quashed conviction of murder and subbed one for manslaughter.

1. How probably was the consequence which resulted of D's voluntary act?

2. Did D forsee that consequence? 

'virtual certainty' 

D threw a baby at a pram some 3-4 feet away. The baby hit the wall and later died of injuries to his head. 

Find rather than infer as opposed to Nedrick. 

Problems with find? Used in the Criminal Justice Act 1967.

Does it improve the direction of the jury? 

Does find mean foresight or just evidence of it?

D's dropped V into a river knowing he couldn't swim, saw him doggy paddle towards the bank and assumed he'd make it out alive and left. 

D's knew it was a virtual certainly and they did not attempt to save him. 

Woollin (1998) meant foresight of consequences is not intention. Jury are entitled to find evidence of intention but do not have to.